Originally Posted by
Edreyn
As far as I familiar with Planescape settings, in some cases souls can end up not in generic hell, but in a "private" territory of a deity.
We are talking about really evil people. Those who commit really evil things, will surely catch an interest from someone among deities. They can't get redemption, but maybe they can convince a cleric of same evil alignment, to pray and ask some evil deity to give shelter. As long as it's still on the same lower plane, it shouldn't break any Multiverse laws.
Existence in the territory of a specific deity is still not much of a paradise, but still much less horrid then "standard" lower plane. In some cases, even just after rebirth petitioner will be tormentor and not one tormented.